Bulletins from the Pacific Packet Radio Society - page 093

deregulatory effort in the area of Amateur Radio digital electronic experimentation, thus facilitating accomplishment of the amateur's duty to contribute to the advancement of the radio art. Since 1978, amateurs in the United Kingdom and elsewhere 12/ have experimented with AMTOR as a means of securing error-free teleprinter operation in the high-frequency bands. To date, some 40 amateurs are active with AMTOR. The Amateur Radio regulations of Australia, the United Kingdom and West Germany now permit i t s operation. Several U.S. amateurs 13/ have under Special Temporary Authority conducted experiments with AMTOR. it is the League's understanding that such authority has been renewed, and that preliminary reports filed by those experimenters are on file with the Commission. The consensus of those operators is that AMTOR does indeed provide nearly error-free transmission even with fading or otherwise marginal propagation conditions.

Wherefore, the premises considered, the American Radio Relay League, Incorporated respectfully requests that the Commission issue a Notice of Proposed Rule Making at any early date, proposing amendment of Section 97.69 of its rules to permit the use of the digital code specified in Recommendation 476-2 (1978) of the International Radio Consultative Committee, known in the Amateur Radio Service as AMTOR9 in the amateur high-frequency bands.

Respectfully submitted,

The American Radio Relay
225 Main Street League, Incorporated
Newington, CT 06111

By Christopher D. Imlay
Its Counsel

May 26, 1982

1/ The League gratefully acknowledges the extensive and helpful assistance of Mr. Bill Meyn, K4PA9 in the preparation of this Petition.

2/ Attached hereto as Exhibit A.

3/ 20 Millisecond changeover time is typical.

4/ See Section 97.1(b) of the Commission's Rules.

5/ Article I, Section II.

6/ A similar definition appears in Section 97.3(a) of the Commission's Rules.

7/ FCC 80-35, 45 Fed. Reg. 8990.

8/ Notice of Proposed Rule Making, FCC 81-459, 46 Fed. Reg. 50993 et seq., released October 9, 1981.

9/ See attached Appendix, Exhibit C.

10/ See Third Report and Order, Docket 20777, 45 Fed. Reg. 8990.

11/ Article 41, Section 2, Paragraph (1) requires, inter alia, that amateur transmissions be made in "plain language". It is presently unclear how this requirement may be interpreted with respect to digital radio teleprinter codes in general.

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